What is the Stop-the-Clock mechanism in the EU Omnibus Simplification Package?

The Stop-the-Clock mechanism delays the reporting deadlines under the CSRD and CS3D. It gives large companies and listed SMEs more time to prepare by pushing back CSRD reporting for second- and third-wave companies by two years and delaying the CS3D start date by one year.

Does the Stop-the-Clock mean companies can pause CSRD or CS3D preparation?

No. The directives still apply, and companies should continue building their sustainability data programs. The delay offers time to simplify processes — but reporting requirements remain.

Are non-EU companies affected by the CSRD or CS3D delays?

Non-EU companies with EU customers or operations still need to collect supply sustainability data. The timeline postponement gives non-EU companies more time to get their sustainability programs in order.

What are conflict minerals and why are they important in 2025?

Conflict minerals include tin, tungsten, tantalum, and gold (3TGs). Many companies also have responsible sourcing programs for cobalt, lithium, and mica. In 2025, due to rising global conflicts and new sanctions, sourcing these minerals responsibly is more critical than ever to avoid non-compliance and supply chain risks.

What’s new in conflict minerals compliance for 2025?

Key updates include increased conflict in the eastern Democratic Republic of the Congo (DRC), new sanctioned smelters, and the addition of an RMAP-compliant smelter to the UFLPA Entity List. Companies need RCOI data, not just smelter compliance, to stay ahead.

What is RCOI and why is it essential for compliance?

RCOI stands for Reasonable Country of Origin Inquiry. It ensures companies trace minerals back to their source, not just the smelter. In 2025, RCOI data is crucial to meeting legal requirements and avoiding hidden compliance risks.

What is the CMRT and how is it used?

The Conflict Minerals Reporting Template (CMRT) is a standardized form used to gather data on 3TG minerals from suppliers. It helps companies comply with regulations like the Dodd-Frank Act by identifying smelters and countries of origin.

How can companies build a strong conflict minerals compliance program?

Companies should perform a scope analysis, create a clear compliance plan, collect accurate supplier data using the CMRT, and monitor regulatory updates. Tools like Assent’s solution support reporting, smelter risk assessment, and RCOI data collection.